IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF MISSISSIPPI
JACKSON DIVISION

UNITED STATES OF AMERICA,

Plaintiff,

GAIL GRAHAM,

Plaintiff-Intervenor,

v. Civil Action No. 3:99-cv-556WS

L.T. JACKSON;
L.T. JACKSON TRUST;
BETTYE HART,

Defendants.

__________________________

AMENDED COMPLAINT & DEMAND FOR JURY TRIAL

The United States of America alleges:

This action is brought by the United States to enforce the provisions of Title VIII of the Civil Rights Act of 1968 (the Fair Housing Act), as amended by the Fair Housing Amendments Act of 1988, 42 U.S.C. §§ 3601, et seq.

Defendant L.T. Jackson is a resident of the State of
Mississippi in the Southern District of Mississippi. Mr. Jackson
is the owner and/or manager of numerous identified rental
properties in the Jackson, Mississippi area, including, but not
limited to, properties located at 5635 Queen Eleanor Lane, 309
North Prentiss Street, 4620 Kirley Drive, 631 Tifton Drive, and
166 York Drive. Mr. Jackson has owned and/or personally managed
these rental properties at all times relevant to this case.

Defendant L.T. Jackson Trust, located in the Southern
District of Mississippi in Canton, Mississippi, owns and/or
manages most or all of the rental properties at issue in this
case.

Defendant Bettye Hart is a resident of State of
Mississippi in the Southern District of Mississippi. Ms. Hart
has been, since at least June, 1998, the owner of a rental
property located at 631 Tifton Drive in Jackson, Mississippi.
Defendant L.T. Jackson personally managed such property at all
times relevant to this case. Ms. Hart was the owner of such
property at times when female tenants of the property were
subjected to discrimination as described herein.

The identified rental properties owned and/or managed
by defendants are dwellings within the meaning of 42 U.S.C. § 3602(b).

The defendants have violated the Fair Housing Act, 42
U.S.C. §§ 3601, et seq., by discriminating against persons on the basis of sex in connection with the rental of dwellings

Since at least 1992 through the present, defendant,
L.T. Jackson, has subjected numerous female tenants (and, on some
occasions their minor daughters), and prospective female tenants
of the rental properties owned and/or managed by defendants, to
severe, pervasive, and unwelcome verbal and physical sexual
advances. On numerous occasions, defendant, L.T. Jackson, made
sexually suggestive comments to both the female tenants and their
teenage daughters. Jackson also made physical advances towards
the tenants such as unwanted touching of their breasts, buttocks,
and other parts of their bodies.

Defendant, L.T. Jackson, has explicitly based the
terms, conditions, and privileges of the women's tenancy at the
properties owned and/or managed by defendants on the granting of
sexual favors. For example, Jackson requested sexual favors from
the female tenants in exchange for forgiveness of rent, late rent
charges, and security deposits. Jackson also threatened to take
steps to evict female tenants who refused or objected to his
sexual advances, and threatened other adverse action against the
female tenants when they refused or objected to his sexual
advances.

The consistent pattern of sexual advances towards
female tenants and prospective tenants has created a longstanding
hostile environment for female tenants living at defendants'
properties.

The conduct of the defendants described in paragraphs
6-10 constitutes:

A denial or making unavailable of housing because of sex, in violation of Section 804(a) of the Fair Housing Act, 42 U.S.C. § 3604(a);

Discrimination in the terms, conditions, or
privileges of the rental of dwellings, or in the
provision of services or facilities in connection
therewith, because of sex, in violation of Section
804(b) of the Fair Housing Act, 42 U.S.C. § 3604(b);

The making of statements with respect to the
rental of dwellings that indicate a preference,
limitation, or discrimination based on sex, in
violation of Section 804(c); and

Coercion, intimidation, threats, and interference
with persons in the exercise or enjoyment of, or
on account of their having exercised or enjoyed
their rights under Section 804 of the Fair Housing
Act, in violation of Section 818 of the Fair
Housing Act, 42 U.S.C. § 3617.

The conduct of the defendants described above in
paragraphs 6-10 constitutes:

A pattern or practice of resistance to the full
enjoyment of rights granted by the Fair Housing
Act, 42 U.S.C. §§ 3601 et seq.; and

A denial to a group of persons of rights granted
by the Fair Housing Act, 42 U.S.C. §§ 3601 et seq., which denial raises an issue of general
public importance.

There are numerous persons, including past, current,
and prospective tenants, who have been injured by, and have
suffered damages as a result of, the defendants' conduct. These
persons are aggrieved persons as defined in 42 U.S.C. § 3602(i)

a) The defendants' above-described conduct was intentional, willful, and taken in disregard for the rights of others; and

b) The conduct of defendants L.T. Jackson Trust and Bettye Hart, as described herein, was negligent because these defendants knew or should have known about the harassment and failed to stop it; because these defendants failed to prevent or correct the harassment; and because these defendants failed to exercise reasonable care in training, hiring, education, and supervision of the employees of the properties described herein.

WHEREFORE, the United States prays that the Court enter an
ORDER that:

Enjoins the defendants, their agents, employees, and
successors, and all other persons in active concert or
participation with him from:

Discriminating on the basis of sex against any
person in any aspect of the rental of a dwelling;

Interfering with or threatening to take any action
against any person in the exercise or enjoyment of
rights granted or protected by the Fair Housing
Act, as amended; and

Failing or refusing to take such affirmative steps
as may be necessary to restore, as nearly as
practicable, the victims of the defendants' past
unlawful practices to the position such victims
would have been in but for the discriminatory
conduct of the defendants;

Awards such damages as would fully compensate each
identifiable victim of defendants' discriminatory housing
practices for injuries caused by the defendants' discriminatory
conduct, pursuant to 42 U.S.C. § 3614(d)(1)(B);